CELSO M.F.L. MELGAR v. PEOPLE

FACTS:

Celso M.F.L. Melgar (Melgar) was charged with violation of Section 5 (e) of Republic Act No. (RA) 9262, otherwise known as the "Anti-Violence Against Women and their Children Act of 2004." The information alleged that Melgar, with deliberate intent, committed acts of economic abuse against AAA and her minor son BBB by depriving them of financial support, causing mental or emotional anguish. A compromise agreement was reached between Melgar and AAA on the civil aspect of the case, resulting in the provisional dismissal of the criminal aspect. However, the prosecution later moved to set aside the compromise agreement and revive the criminal action, claiming that Melgar sold the property intended to answer for the support-in-arrears of BBB. The trial court revived the criminal aspect of the case and allowed the prosecution to present evidence. AAA testified that Melgar stopped providing support for her and BBB, despite being able to afford it. Melgar failed to appear during trial, and the trial court found him guilty of committing economic abuse. Melgar appealed to the Court of Appeals (CA), but his conviction was affirmed. Dissatisfied, Melgar filed a petition for review on certiorari before the Supreme Court. The issue for resolution is whether the CA correctly upheld Melgar's conviction.

ISSUES:

RULING:

PRINCIPLES:

  • Economic abuse is a form of violence against women and their children under RA 9262.

  • A person who has the means to support another and deliberately and with evident bad faith fails to give support to the latter is guilty of economic abuse.

  • The act of depriving a person of financial support, which causes mental or emotional anguish, public ridicule or humiliation, constitutes economic abuse under RA 9262.

  • The acquittal or conviction of a person charged with a crime is not a matter of right, but is entirely within the discretion and sound judgment of the trial court.